Cotton Boll Weevil: An Evaluation of USDA Programs : a Report (1981)

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3. PUBLICLY SUPPORTED PEST CONTROL LEGISLATIVE HISTORICAL BACKGROUND Not long after Congress authorized the establishment of USDA in l862, the department's commissioner of agriculture recommended establishing a "professorship of entomology," saying "insects are annually destroying vast amounts of the product of our soil and their ravage appears to be increasing." Even though subsequent annual reports of USDA's Division of Entomology contained many references to the damaging losses caused by insect pests of foreign origin, little consideration was given to enacting national legislation to prevent or restrict the introduction of additional plant pests. In l88l, California became the first state to enact a plant quarantine law. This act enabled California to enforce inspection and other measures to prevent the entry of pests. In l889, the state of Massachusetts gave its department of agriculture funds to carry out the task of exterminating the gypsy moth. This work was discon- tinued in l900, but the appearance of the gypsy moth in adjacent states during the next five years led Congress to appropriate federal funds to control the gypsy moth in l906. The appropriation act directed USDA to cooperate with state authorities in preventing the further spread of the gypsy and browntail moths. This legislation established the policy of federal-state cooperation in plant pest control programs. Meanwhile, all but five of the states had followed California's lead in establishing a quarantine law. Six years later, in l9l2, the national Plant Quarantine Act [7 U.S.C. l5l-l67] authorized the creation of a plant inspection system and measures to control and eradicate plant pests. State employees were to perform most of the actual examinations at state expense, however. In l9l8 the Mexico Border Act [7 U.S.C. l45], provided federal funds for surveys to determine the distribution of the pink bollworm in states adjacent to the Mexican border, for the establishment of cotton-free zones in states adjacent to the border, for cooperation with Mexico in exterminating infestations near the border, and for 42

43 cooperation with Texas or any other state in stamping out infesta- tions. Prior to the discovery of the pink bollworm in Texas in l9l7, state authorities had already taken steps to enact legislation autho- rizing quarantine regulations and the establishment of cotton-free zones. The state of Texas subsequently instituted a pink bollworm quarantine in January l9l8, and in February of that year a proclama- tion of the governor prohibited the growing of cotton in designated districts for a period of three years or as long as the pink bollworm remained a menace. This attempt at eradication failed owing to a lack of grower support and cooperation. Congress recognized the need for national authority to prevent the introduction of foreign pests and to control any pests that become established when they enacted the Plant Quarantine Act of l9l2, as amended (7 U.S.C. l47a); Public Resolution No. 20, l937 (U.S.C. l48-l48e); and the Cooperation with States Act, l962 (U.S.C. 450). This legislation authorized the Department of Agriculture to: • restrict and control the entry and interstate movements of plants and plant products to prevent the entry and interstate spread of plant pests; • cooperate with the states, farmers, farmers' associations, and Mexico to control or eradicate pests that pose a signifi- cant economic hazard; and • cooperate with state agencies in the administration and enforcement of federal laws and regulations related to the control or eradication of plants pests. Since the passage of the Plant Quarantine Act of l9l2, USDA has developed four strategies for dealing with foreign or, where the strategies are applicable, domestic plant pests: • exclusion: prevention of entry by plant quarantine and inspection; • eradication: early detection of infestations and the use of eradication techniques that are biologically, environmentally, economically, and socially appropriate; • retardation: the use of domestic quarantines to prevent artificial spread of the pest and use of population suppres- sion to retard natural spread; • mitigation: learning to live with the pest through changes in plant cultivation practices and pest control techniques. In l926, however, the U.S. Supreme Court ruled that state quarantines were illegal and unwarranted, and invalidated more than 200 such quarantines. Later that same year Congress amended the Plant Quarantine Act of l9l2 to grant to states the right to take

44 interstate quarantine action against any plant pest not covered by a federal quarantine, to authorize the Secretary of Agriculture to cooperate with any state or territory in the enforcement of such quarantines, and to authorize any state to exercise its police powers with respect to any articles shipped in violation of a federal plant quarantine. In l937 Congress authorized an appropriation of $2 million for the general control of incipient and emergency outbreaks of insect pests and plant diseases. Prior to l937, Congressionally appropriated funds were for specifically named plant pest and disease control programs. In l962 Congress enacted the Cooperation with States Act [7 U.S.C. 450] , directing the Secretary of Agriculture to cooperate with state agencies in the administration and enforcement of federal laws and regulations related to the marketing of agricultural products and to the control or eradication of plant and animal diseases and pests. While many other federal statutes authorize or direct federal/state cooperation, most of them impose qualifying restrictions on coopera- tive activities. Under the l962 Act the Secretary was authorized to enter into cooperative arrangements to the extent he deemed appropri- ate in the public interest. States within geographical regions have also organized among themselves to control the spread of plant diseases and insect pests. In l9l9 the plant regulatory officials of the ll western states, the territory of Hawaii, Mexico's District of Lower California, and Canada's Province of British Columbia formed the Western Plant Quar- antine Board "to secure a greater mutual understanding, closer coop- eration and uniformity of action for the efficient protection of our plant industries against plant diseases and insect pests" (Hagan l9l9) . Central and Eastern Plant Boards were formed in l925, while the Southern Plant Board was formed in l926. These four regional boards then united to form the National Plant Board. While the National Plant Board has no statutory authority, it has considerable influence on policy decisions concerning both domestic and foreign quarantines. In l93l the regional plant boards and the National Plant Board adopted the Principles of Plant Quarantines, which, with slight revision in l936, have provided a sound basis for the initiation of quarantine action. A supplemental document called Definitions and Guidelines was adopted in l969 (Spears l974). In l973, the Plant Protection and Quarantine Division of the USDA Animal and Plant Health Inspection Service (APHIS), in cooperation with the plant boards approved Guidelines for Initiating and Discontinuing State/ Federal Plant Protection Programs (USDA:APHIS:PPQ, March l2, l973). These documents have helped to mold federal publicly supported pest control programs. USDA's procedures for such programs are set forth in Criteria for Participation in Cooperative Plant Protection Pro- grams (USDA:APHIS:PPQ:Draft Oct l976). Most federal appropriations of funds for specific insect pest control programs have stated the program objective to be eradication of the pest, even when technology and resources available for the program have offered little chance of eradication. Many cooperative

45 federal-state pest control programs have been efforts to retard the spread of pests, or combinations of suppression measures to prevent artificial spread of the pest with eradication measures applied to isolated infestations. The Animal and Plant Health Inspection Service (APHIS) of USDA lists 37 plant pests that have been successfully eradicated through state and/or federal action from a limited geographic area in the continental United States (Table 3.l). In general most of the pests on the list are those with limited capability of migration. They had not yet spread to the full potential of their ecological range across the United States and the infestation that was successfully eradi- cated was of limited geographical distribution. COTTON INSECT PESTS The policy of the federal government and of the interested state governments has been to cooperate with cotton growers themselves in aggressive efforts to curb the substantial damage to cotton crops caused by the boll weevil and other cotton insect pests. As Chapter 2 notes, the last two decades have been marked by a host of scientific developments in efforts to deal with cotton insect pests—the contin- ued introduction of new insecticides to replace those rendered less effective by the development of resistance in the insects, efforts to breed new strains of cotton that will have more natural resistance to insect attack, the discovery of the boll weevil pheromone called grandlure and its use in traps for monitoring boll weevil movements, the development of methods for the mass rearing of boll weevils in laboratories, attempts to use mass sterilization of male boll weevils to reduce weevil populations, and, last but not least, discovery of the value of using insecticides against boll weevils at the end of the cotton season to kill diapausing weevils that would otherwise survive the winter and begin to breed anew the following year. Most of these developments have had their origin, in the last analysis, in the desires of cotton growers themselves to minimize the economic damage they suffer from cotton insect pests every year. In l969 the National Cotton Council of America, the largest organization of cotton growers, formally asked USDA to conduct an experiment in the heart of the Cotton Belt to determine if it was technically feasible to eliminate the boll weevil, using the newest techniques then available. Such a trial was conducted in an area of south Mississippi between l97l and l973. During the trial, known as the Pilot Boll Weevil Eradication Experiment (PBWEE), boll weevil popula- tions were suppressed to very low levels. In August l973 the techni- cal guidance committee of the National Cotton Council reviewed the data from the PBWEE experiment and concluded that it was technically and operationally feasible to "eliminate as an economic pest" the boll weevil in the United States by using techniques that were also ecologically acceptable. A new federal law was enacted that same month authorizing and directing the Secretary of Agriculture "to carry out programs to

46 TABLE 3.1 Successful Plant Pest Eradication Programs from Conterminous United States, APHIS Pest and (Host) Year and Location Primary Method Used for Eradication INSECT PESTS Melanaspis aliens (Newstead)—alien scale (orchids) 1958-71-Florida Phosphatic sprays and infested host destruction. Nygmia phaeorrhoea (Donovan)-browntail moth 1911-48- Vermont Manual destruction of webs and lead arsenate sprays to foliage. 1911-69-New Hampshire DDT and caibaryl foliar sprays. Manual destruction of webs. Aleurocanthus woglumi (Ashby)—citrus blackfly (citrus, mango) 1934-38 -Florida" Destruction and oil sprays of infested host trees. Rotenone and oil sprays. 1956-Texas* Parlatoria blanchardi (Targioni-Tozzetti)-date palm scale or parlatoria date scale (palms) 1913-36—California, Arizona, Summer oil sprays. Texas Eriophyes litchii (Keifer)-erinose mite (lychee) 1956-58-Florida Dicofol sprays and sanitation. Rhizotrogus majalis (Razoumowsky)-European chafer (roots of turf, trees, and shrubs) 1954-65-West Virginia Dieldrin surface treatment. Lymantria dispar (Linnaeus)-gypsy moth (oak and other hardwood foliage) 1914-17-Ohio Arsenate of lead. 1954-65-Michigan DDT foliar sprays. 1966-70-Michiganc Carbaryl foliar sprays. Nilotaspis halli (Green)-hall scale (stone fruits) 1941-67-California HCN fumigation. Solenopsis invicta (Buren)-red imported fue ant Solenopsis richteri (Forel)-black imported fire ant 1950-Tennessee Chlordane surface treatment. 1966-Tennessee Mirex bait. PopUlia japonica (Newman)-Japanese beetle (turf, flowers, grapes,. .. general feeder) 1957-65-Iowa Dieldrin surface treatment. 1961-65-California (Sacramento) Chlordane surface treatment; carbaryl foliar treatment. 1972-76-California (San Diego) Chlordane surface treatment; carbaryl foliar treatment. Trogoderma granarium (Everts)-khapra beetle (stored grains) 1954-66-Texas, Arizona, New Methyl bromide fumigation. Mexico, California Ceratitis capitata (Wiedemann)-Mediterranean fruit fly (fruits and vegetables) 1929-30-Florida Host fruit destruction and bait sprays. 1956-58-Rorida Malathion bait sprays, trapping and lures. 1963 (two occasions)-Florida Malathion bait sprays, trapping and lures. 1966-Texas Malathion bait sprays, trapping and lures. 1975-76-California Host fruit destruction, traps, ground treatment with insecticides and sterile releases. 1980-California^ Traps, ground treatment with insecticides and sterile releases. Dacus cucurbitae (Coquillett)-melon fly (cucurbits-melons, etc.) 1957-California Trapping.

47 TABLE 3.1 (continued) Pest and (Host) Year and Location Primary Method Used for Eradication Epilachna varivestis (Mulsant)-Mexican bean beetle (beans) 1950-California Foliar sprays with Rotenone. Anastrepha ludens (Loew)-Mexican fruit fly (citrus) iM-t California Malathion bait spray. Eurytoma sp. or Eurytoma orchidearum (Westwood)—orchidfly (fox-tailed orchid)—a chalcid wasp 1966-68-Florida Uiniethoate, diazinon, and sanitation. Asterolecanium epidendri (Boisduval)-orchid pit scale (orchids) 1968-71-Florida Destruction of infested plants. Dacus dorsalis (Hendel)-Oriental fruit fly (citrus) 1960-California Methyl eugenon trapping. 1966-California Methyl eugenon trapping. 1969-78-California each year Methyl eugenon trapping and methyl eugenon/naled bait. Reintroduced each year from 1970 to 1978 and eradicated each year. Pectinophora gossypiella (Saunders)-pink bollworm 1933-35 -Georgia Nonplanting zone. Ceroplastes rubens (Maskell)-red wax scale (Chinese evergreen, anthurium, etc.) 195 5-60- Florida Dimethoate sprays and sanitation. 1961-68-Florida Dimethoate sprays and sanitation. Vinsonia stellifera (Westw.)-stellate scale (orchids) 1955-58-Florida Parathion and oil sprays and parathion clips. Cylas formicarius elegantulus (Summers)-sweetpotato weevil (sweetpotato) 1962-New Jersey Host destruction, dieldrin surface treatment. Graphognathus spp. -whitefringed beetles (roots of crops - peanuts and foliage of truck crops) 1954-60-New Jersey Dieldrin soil and soil surface treatments. 1%5-70 Maryland Dieldrin surface treatments. Has been reintroduced 1979. PLANT DISEASES Xanthomonas citri (Hasse)-citrus canker (citrus) 1914-43-Florida and Gulf Destruction of infected host. States to Tenas Puccinia sorghi- common maize rust (corn) 1969-70-Florida Destruction of infected host. Physopella pallescens (Arth. Cumm. and Ram.)-gamagrass rust (Tripsacum and Euchlaena) 1970-72-Florida Destruction of infected host material. (virus disease)-Hoja Blanca virus 1957-65-Florida Malathion sprays, roguing and plowing under. / (Mycoplasm disease)-lethal yellowing of coconuts Cocunut Lethal Yellowing Mycoplasm 1955-68-Florida, Key West Resistant Malayan varieties. Has been reintroduced. Peach Mosaic Virus 1935-70-Utah Destruction of infected trees.

48 TABLE 3.1 (continued) Pest and (Host) Year and Location Primary Method Used for Eradication Puccinia pelargonti - zonalis (Doidge)-pelargonium (geranium) rust 1970-71 -Florida Dithane, zineb sprays, sanitation, and destruction of infected plant. Uredo becknickiana (P. Henn)-Phajus rust (orchids) 1954-Florida Destruction of infected plants. Synchytrium endobioticum (Schibb. Perc.)-potato wart (potato) 1918-74 -Maryland, West Host destruction. Virginia, Pennsylvania Soil treatment with copper sulfate or formaldehyde. Physopella zeae (Mains, Cummings, and Ramacher)-tropical corn rust 1970-Florida Destruction of infected plants. OTHER Helin aspersa (Muller)- brown garden snail (plant feeder) 1963-64-Florida Menacarbate and methyl bromide fumigation. 1964-66-Florida Mexacarbate. 1969-70 Florida Methaldehyde-calcium arsenate bait applied aerially. Achatina fulica (Bowdich)-giant African snail (plant feeder) 1969-75-Florida Methaldehyde-calcium arsenate bait, carbaryl drenches, handpicking sanitation. Globodera rostochiensis-go\den nematode (potato, tomato) 1968-70-Delaware DD soil fumigation. Theba pisana (Muller)-white garden snail 1927-California Methaldehyde bait. 1940-California Methaldehyde bait. 1956-South Carolina Methaldehyde bait. 1969-California Calcium arsenate bait. "Reintroduced, Fort Lauderdale, Florida, 1976. ''Reintroduced, Brownsville, Texas, 1971. cReintroduced, Michigan, 1972. ^Reintroduced, San Jose, California, 1980. SOURCE: M. J. Pender, APHIS, personal communication, 1981.

49 destroy and eliminate cotton boll weevil in infested areas of the United States ... if the Secretary determines that methods and systems have been developed to the point the success in eradication of such insect is assured ..." The new law also required cotton growers to pay up to one-half of the costs of what the law also referred to as an "eradication" program and gave the Secretary the authority to issue "such regulations as he deems necessary to enforce the provisions of this subsection with respect to achieving the compliance of producers and landowners." This last proviso, in effect, gave the Secretary full authority to carry out the program, including enforcing the program among all cotton growers and allowing federal officials to enter any private property necessary for success of the program. The provision was a departure from historical practice, in which the states had been vested with authority for enforcement and right-of-entry in insect pest control programs, and was a logical extension of the following statement in the National Plant Board's l972 Principles of Plant Pest Control: "Since the measures required to implement a pest control program usually involved treatment of private and public property for the benefit of wider interest or the public welfare, they could not be undertaken by private individuals or groups, and therefore to resort to procedures under public authority is logical." The PBWEE experiment and the l973 legislation, however, did not settle the question of how to deal with the boll weevil. As the National Cotton Council's technical guidance committee had already recognized, some boll weevils had been found in the PBWEE "eradica- tion zone." This technical guidance committee took the view, how- ever, that what PBWEE had demonstrated was eradication followed by reinfestation. Since boll weevils can migrate at least 45 miles (72 km), and since most of the cotton in the eradication zone was within 45 miles of infested cotton, the technical committee took the view that the boll weevils found in the zone were immigrants. In order to describe what had happened, the committee said that the boll weevils in the zone had been "eliminated as an economic pest" rather than "eradicated." In l973 a committee of the Entomological Society of America evaluated the PBWEE experiment. That committee expressed reser- vations about undertaking any massive program of boll weevil eradi- cation until the techniques used in PBWEE were improved and more attention was paid to the problem of preventing a boll weevil immigration from Mexico in the event boll weevils actually were eradicated from the United States. In l975 the National Academy of Sciences published a report in which a subcommittee on cotton pest control expressed severe doubt as to the feasibility of eradicating the boll weevil in this country (NRC l975). Meanwhile, the agricultural appropriation subcommittee of the House Appropriations Committee had begun to express concern about the l973 law granting new powers to the Secretary of Agriculture. The subcommittee was concerned about whether the powers granted to the Secretary to carry out the law for controlling the boll weevil amounted to control of private land use by the federal government; it

50 was also concerned about insufficient cooperation with USDA's boll weevil control efforts among cotton growers and the states. Despite the reservations in various quarters about the results of the PBWEE experiment and about the l973 federal legislation, the National Cotton Council continued to support a plan it had submitted to the Secretary of Agriculture for eradicating the boll weevil. A number of conditions have been identified as essential to the success of any effort to eradicate the boll weevil (Brazzel l976, Guice l976). They are as follows: • There must be overwhelming support of the program by growers, by private industry, and by federal and state agencies. • There must be participation by l00 pecent of the growers. • Either federal or state governments must have the authority to do the following: establish an eradication zone; grant program inspectors the authority to enter any public or private property in the zone; prohibit the non-commercial raising of cotton; regulate the movement of seed cotton and any other material capable of transporting boll weevils; require mandatory reporting of all cotton acreage; and allow the destruction of volunteer cotton. • Growers must be willing to contribute up to 50 percent of the cost of the program. As indicated earlier, all of the states have the statutory authority to regulate the interstate and intrastate movement of insect pests and plant diseases, and most of them have the authority to control specified plant pests through quarantine or other methods. A review of Bruer (l976) showed, however, that most of the states lacked authority to compel cooperation with one or more of the condi- tions noted by Brazzel and Guice. Bruer concluded that if any eradi- cation program was to be successful, "some revision of state statutes seems to be indicated." Another problem, and one that has aroused substantial debate ever since the National Cotton Council proposed its plan to the Secretary of Agriculture in l973, is whether or not "eradication" is desirable, even if feasible. Part of the disagreement over such a plan comes from the diffi- culty in defining the term "eradication." While eradication clearly means "to eliminate the population of boll weevils," the questions that must be asked are, For how long? and Throughout what geographi- cal area? In the past these questions have been left unanswered in official documents and hence subject to virtually innumerable inter- pretations. As Table 3.l shows, success in eradication in the past has only been obtained for a limited time and in limited areas for other insect pests in the United States. If both the timespan and area of eradication are narrowly defined, these eradication efforts can be termed successful. But if broader definitions are used—for

5l example, eradication for a decade throughout the United States—very few of the eradication programs shown in the table have been successful. Eradication of a specific pest from a specific area is likely to be the most effective and efficient strategy only when an effective and economical eradication technique is available and when the pest in question is not widely distributed. This is often the case if the pest has recently invaded an area and has a limited habitat. Other- wise, it makes sense from an ecological standpoint to approach the task of eradication cautiously. Because the suggested plan to eradicate the boll weevil tended to polarize proponents and opponents of the plan, USDA decided in l977 to conduct two kinds of trials. One was the Boll Weevil Eradi- cation (BWE) trial, to be conducted in adjacent areas of North Caro- lina and Virginia, and designed to wipe out the insect completely. The other was the Optimum Pest Management (0PM) trial in Mississippi, designed to determine whether it was possible to hold boll weevil populations below levels that are economically harmful to cotton growers. The BWE and OPM trials are described in some detail in the next chapter.